Buenconsejo v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Petitioner Floro Buenconsejo filed his certificate of candidacy for president of the Union Obrera de Tabaco for the election scheduled on March 1, 1964. The union returned his certificate of candidacy on February 14, 1964, citing unstated reasons known to petitioner. Petitioner filed a charge of unfair labor practice against the union and Tito Bilangel, the sole candidate for president, on February 10, 1964. Procedural History: Incident to the unfair labor practice case, petitioner filed an Urgent Petition for Preliminary Injunction with the Court of Industrial Relations (CIR) on February 25, 1964, seeking to be included as a candidate in the March 1, 1964 election. Despite urgent motions filed by petitioner on February 20, 1964, and a few days later, the CIR had not acted on his petition for injunction, with less than five days remaining before the election involving 1,500 employees. The Petition: Contending that the CIR's inaction would exclude him from the election, petitioner filed an original action for mandamus with preliminary injunction before the Supreme Court, seeking his inclusion as a candidate. The Supreme Court issued a resolution on February 28, 1964, requiring respondents to answer and issuing a preliminary mandatory injunction ordering the CIR to act on the complaint and petition for injunction due to the scheduled election.
Issue(s)
Whether the petition for mandamus to compel the Court of Industrial Relations to include petitioner as a candidate remains a justiciable controversy after the election has already been conducted.
Ruling
The petition is dismissed as moot and academic, for lack of justiciable controversy. No pronouncement as to costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petition must be dismissed because it has become moot and academic. A justiciable controversy exists only when there is an actual dispute that can be settled by the court through the grant of practical relief. In this case, the specific relief sought by Buenconsejo was his inclusion as a candidate for the union presidency in the election held on March 1, 1964. However, the record shows that the election was already regularly held as scheduled. The petitioner's failure to participate was attributed to his inability to post the required bond for the preliminary mandatory injunction in the Court of Industrial Relations (CIR). Because the election is a past event, any declaration by the Court regarding the petitioner's candidacy would have no practical effect or value. Therefore, the supervening event of the concluded election removed the necessity for a judicial determination, leaving the Court with no live controversy to resolve.
Main Doctrine
A petition for mandamus with preliminary injunction seeking inclusion as a candidate in a union election is dismissed as moot and academic when the election has already been held and the petitioner failed to secure the injunctive relief due to inability to post the required bond.